Privacy Policy

Effective as of January 1, 2020. You can see the prior versions here

Zeel Networks, Inc. (“Zeel,” “we,” “us” or “our”) connects massage therapists with customers seeking on-demand massages. This Privacy Policy describes how we collect, use and share personal information in connection with our websites (collectively, the “Site”), mobile applications (collectively, the “App”), and other digital platforms that link to this Privacy Policy (together with the Site and App, the “Service”); our marketing communications; and in certain offline settings where we post this Privacy Policy.

We provide important information for California residents here

Table of Contents

• Personal information we collect
• How we use your personal information
• How we share your personal information
• Your choices
• Other sites and services
• Security
• International data transfer
• Children
• Changes to this Privacy Policy
• How to contact us
• Important information for California residents

Personal information we collect

Information you provide to us. Personal information you may provide to us through the Service or otherwise includes:

• Contact data, such as your first and last name, email and mailing addresses, residence, postal code, phone number, professional title, and organizational affiliation.
• Profile data, such as your username and password that you set to establish an online account with us, age, gender, biographical details, photograph, links to your profiles on various third party sites including social networks, and massage preferences including any health information you choose to provide.
• Identity data that we collect to conduct identification verification and security checks (or in the case of massage therapists, background checks and other screens permitted by law), such as a social security number, tax identification number, passport number, state or local identification number, or professional license number, and an image of the relevant identification card.
• Data about others for whom you schedule a massage, such as the massage recipient’s full name, phone number, email address, gender, birthday. Please do not schedule a massage for someone or share their contact information with us unless you have their permission to do so.
• Communications that we exchange, including when you contact us with questions, feedback, or otherwise.
• Transactional data, such as the information needed to complete your orders and/or payments on or through the Service (including name, credit card information, bank account number, billing and shipping information, insurance information), and information about payments to and from you and other details of products or services you have purchased from us.
• Marketing data, such as your preferences for receiving communications about our products, activities, events, and publications, and details about how you engage with our communications.
• Other information that we may collect which is not specifically listed here, which we will use as described in this Privacy Policy or as otherwise disclosed at the time of collection.

Data from other sources. We obtain personal information from other sources, such as:

• Users, including massage therapist providers or customers, who can provide ratings and feedback on their massage experiences through the Services.
• Screening providers, such as providers of background check, credit check, or other screening services.
• Data providers, such as information services and data licensors that provide demographic and other information
• Public sources, such as social media platforms.

Automatic data collection. We, our service providers, and our business partners may automatically log information about you, your computer or mobile device, and your activity over time on our sites and other sites and online services, such as:

• Device data, such as your computer or mobile device operating system type and version number, manufacturer and model, browser type, screen resolution, IP address, IP address, unique identifiers, the website you visited before browsing to our website, and general location information such as city, state or geographic area.
• Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access.
• Precise geolocation data, such as when you authorize our mobile application to access your location.

Cookies. Some of our automatic data collection is facilitated by:

• Cookies, which are text files that websites store on a visitor‘s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently and remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating online advertising.
• Web beacons, also known as pixel tags or clear GIFs, which are typically used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked, typically to compile statistics about usage of websites and the success of marketing campaigns.
• Software development kits, or SDKs, which are used to incorporate third party computer code into our App that allows our third party service providers or advertising partners to collect data directly from it for a variety of purposes, including to provide us with analytics regarding the use of the App, to integrate with social media, add features or functionality to our app, or to facilitate online advertising.

How we use your personal information

We use your personal information for the following purposes or as otherwise described at the time we collect it:

Service Delivery. We use your personal information to:

• provide, operate and improve the Service and our business;
• conduct background checks and other screens permitted by law;
• establish and maintain your user profile on the Service, including allowing users to view profiles of massage therapists;
• process provider payments and related tax filings;
• enable security features of the Service, such as by sending you security codes via email or SMS, and remembering devices from which you have previously logged in;
• communicate with you about the Service, including by sending announcements, updates, security alerts, and support and administrative messages;
• understand your needs, interests, and massage preferences, and personalize your experience with the Service and our communications; and
• provide support for the Service and respond to your requests, questions and feedback.

Research and development. We may use your personal information for research and development purposes, including to analyze and improve the Service and our business. As part of these activities, we may create aggregated, de-identified or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve the Service and promote our business.

Marketing and advertising. We and our third party advertising partners may collect and use your personal information for marketing and advertising purposes:

• Direct Marketing. We may send you Zeel-related or other direct marketing communications as permitted by law, including by email and mail. You may opt-out of our marketing communications as described in the Opt-out of marketing section below.
• Interest-based advertising. We may contract with third-party advertising companies and social media companies to display ads on our Service and other sites. These companies may use cookies and similar technologies to collect information about you (including the device data, online activity data and/or geolocation data described above) over time across our Service and other sites and services or your interaction with our emails, and use that information to serve ads that they think will interest you. These ads are known as "interest-based advertisements." You can learn more about your choices for limiting interest-based advertising, in the Advertising choices section below.

Compliance and protection. We may use your personal information to:

• comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities;
• protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims);
• audit our internal processes for compliance with legal and contractual requirements and internal policies;
• enforce the terms and conditions that govern the Service; and
• prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.

How we share your personal information

We may share your personal information with the following parties and as otherwise described in this Privacy Policy or at the time of collection:

Affiliates. Our corporate parent, subsidiaries, and affiliates, for purposes consistent with this Privacy Policy.

Service providers. Companies and individuals that provide services on our behalf or help us operate the Service or our business (such as IT, hosting, customer relationship management and support, print and mail fulfillment, data management, email delivery, marketing, website analytics, and providers of background, credit, and other screening services).

Advertising partners. Third party advertising companies that collect information about your activity on the Site and other online services to help us advertise our services, and/or use hashed customer lists that we share with them to deliver ads to them and similar users on their platforms.

Professional advisors. Professional advisors, such as lawyers, auditors and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. Law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and operations purposes described above.

Business transferees. Relevant participants in business transactions (or potential transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Zeel or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties on our Service, that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Your choices

You have the following choices with respect to your personal information.

Access or update your Information. If you have registered for an account with us, you may review and update certain account information by logging into the account.

Opt-out of marketing communications.You may opt-out of marketing-related emails by following the opt-out or unsubscribe instructions at the bottom of the email, or by contacting us. You may continue to receive service-related and other non-marketing emails. If you receive marketing text messages from us, you may opt out of receiving further marketing text messages from us by replying STOP to our marketing message.

Cookies. Most browsers let you remove and/or stop accepting cookies from the websites you visit. To do this, follow the instructions in your browser’s settings. Many browsers accept cookies by default until you change your settings. If you do not accept cookies, however, you may not be able to use all functionality of the Service and our Site may not work properly. For more information about cookies, including how to see what cookies have been set on your browser and how to manage and delete them, visit www.allaboutcookies.org. We use Google Analytics to help us understand user activity and patters on the Sites. You can learn more about Google Analytics cookies at https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and about how Google protects your data at http://www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our Sites by downloading and installing a browser plugin available at https://tools.google.com/dlpage/gaoptout?hl=en.

Privacy settings and location data. Users of our App can disable our access to their device’s precise geolocation in their mobile device settings.

Interest-based advertising. Some of our advertising partners are members of the Network Advertising Initiative (NAI) and are subject to the Self-Regulatory Principles for Online Behavioral Advertising published by the Digital Advertising Alliance (DAA). You can obtain more information about these companies' information collection practices, and opt-out of receiving interest-based advertising from participating NAI and DAA members at http://www.networkadvertising.org/managing/opt_out.asp and/or the DAA's website at optout.aboutads.info. Mobile app users may opt out of receiving interest-based advertising in mobile apps provided by participating members of the Digital Advertising Alliance by installing the AppChoices mobile app, available at https://www.youradchoices.com/appchoices. You can also limit collection of your information for interest-based ads by blocking third party cookies in your browser settings or using privacy plug-ins or ad blocking software that help you block third party cookies. In addition, your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for targeted online advertising purposes. If you opt-out of interest-based advertisements, you will still see advertisements online but they may be less relevant to you.

Please note that we also may work with companies that offer their own opt-out mechanisms or do not participate in the opt-out mechanisms described above. Even after using these opt-out mechanisms, you may receive interest-based advertising from other companies.

Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.

Declining to provide information. We need to collect personal information to provide certain services. If you do not provide the information requested, we may not be able to provide those services.

Third party platforms. If you choose to connect to the Service through your social media account, you may be able to use your settings in your account with that platform to limit the information we receive from it. If you revoke our ability to access information from a third party platform, that choice will not apply to information that we have already received from that third party.

Other sites and services

The Service may contain links to websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages, mobile applications or other online services that are not associated with us. We do not control websites, mobile applications or online services operated by third parties, and we are not responsible for their actions.

Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, security risk is inherent in all internet and information technologies and we cannot guarantee the security of your personal information.

International data transfer

We are headquartered in the United States and may use service providers that operate in other countries. Your personal information may be transferred to the United States or other locations where privacy laws may not be as protective as those in your state, province, or country.

Children

The Service is not intended for use by children under 16 years of age. If we learn that we have collected personal information from a child under 16 without the consent of the child’s parent or guardian as required by law, we will delete it.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on the Service. If required by law we will also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email or another manner through the Service. Any modifications to this Privacy Policy will be effective upon our posting the modified version (or as otherwise indicated at the time of posting). In all cases, your continued use of the Service after the posting of any modified Privacy Policy indicates your acceptance of the modified Privacy Policy.

How to contact us

• Email: privacy@zeel.com
• Mail: Zeel Networks, Inc., P.O. Box 5191, New York, NY 10185-5191

Important information for California residents

Scope. This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents when we act as a “business” as defined under the California Consumer Privacy Act of 2018 (“CCPA”), and their rights with respect to their Personal Information. For purposes of this section, “Personal Information” has the meaning given in the CCPA but does not include information exempted from the scope of the CCPA or information we collect from you in the course of providing services to you or receiving services from you where you are an employee, controlling owner, director, officer or contractor of a company, partnership, sole proprietorship, non-profit or government agency. In some cases we may provide a different privacy notice to certain categories of California residents, such as job applicants, in which case that notice will apply instead of this section.

Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
• The categories of Personal Information that we have collected.
• The categories of sources from which we collected Personal Information.
• The business or commercial purpose for collecting and/or selling Personal Information.
• The categories of third parties with whom we share Personal Information.
• Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
• Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
• Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
• Deletion. You can ask us to delete the Personal Information that we have collected from you.
• Nondiscrimination. You are entitled to exercise the rights described above free from discrimination in the form of legally prohibited increases in the price or decreases in the quality of our Service.

We do not sell your personal information

Based on our understanding of the term “sell” under the CCPA, we do not “sell” your Personal Information and have not sold it to third parties for a business or commercial purpose in the 12 months preceding the effective date of this Privacy Policy. However, like many companies online, we use services provided by Google, Facebook and others that help deliver interest-based ads to you as described in the section above entitled Interest-Based Advertising.

How to exercise your rights

You may exercise your right to information, access or deletion by :

• visiting https://www.zeel.com/account/data
• emailing datarequests@zeel.com

We reserve the right to confirm your California residency to process your requests and will need to confirm your identity to process your requests to exercise these rights. Government identification may be required. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government-issued identification, and the authorized agent’s valid government issued identification. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

Personal information that we collect, use and disclose

The chart below describes the Personal Information we collect by reference to the categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Information you voluntarily provide to us, such as in free-form webforms, may contain other categories of personal information not described below. Each category is used for the business/commercial purposes described in the section above entitled How we use your personal information, and disclosed to the categories of third parties described in the section above entitled How we share your personal information.

Statutory category of personal information (PI)	PI we collect in this category (See “Personal information we collect” above for description)	Source of PI
Identifiers (excluding online identifiers)	Contact data Profile data Identity data Data about others	You Users Screening providers Data providers Public sources
Online Identifiers	Device data	Automatic collection
Commercial Information	Contact data Profile data Transactional data Marketing data Online activity data	You Users Data providers Automatic collection
Financial Information	Transactional data	You Data providers
Internet or Network Information	Transactional data Marketing data Device data Online activity data	You Automatic collection
Geolocation Data	Device data Precise geolocation data	Automatic collection Data providers
Inferences	May be derived from your: Contact data Profile data Identity data Data about others	N/A
Professional or Employment Information	Contact data	You Screening providers Data providers
Protected Classification Characteristics	Profile data	You
Education Information	Profile data	Data providers Screening providers
Sensory Information	Profile data	You